William Joel Ashley - Page 14




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          therefore reject petitioner’s claimed casualty loss deduction.              
               B.  Interest and Real Estate Taxes                                     
               Section 163(h) denies deductions for personal interest paid            
          or accrued during the taxable year unless it fits within certain            
          narrowly prescribed categories.  Section 163(h)(2)(D), one of               
          those prescribed categories, allows a deduction for interest on a           
          qualified residence.  Petitioner submitted Forms 1098, Mortgage             
          Interest Statement, to the Court for two personal residences,               
          claiming only one-half of the reported interest as he jointly               
          owns the properties with another individual.  Because his                   
          testimony was consistent with the submitted Forms 1098, we allow            
          the deduction for interest.  We also allow the real estate taxes            
          claimed with regard to the same properties.                                 
               C.  Charitable Contributions                                           
               The next issue for decision concerns petitioner’s claimed              
          deduction for charitable contributions, which respondent                    
          disallowed for lack of substantiation.  Petitioner testified that           
          the claimed contributions were “donations for AIDS, * * *,                  
          support for scholastic issues”, which were collected by                     
          individuals going “door-to-door”.  Section 170(a)(1) provides               
          that a charitable deduction is allowed “only if verified under              
          regulations prescribed by the Secretary.”  For contributions by             

               10(...continued)                                                       
               suffered, and (d) the value of the property after the                  
               repairs does not as a result of the repairs exceed the                 
               value of the property immediately before the casualty.                 
          Petitioner has also failed to prove those requirements.                     





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